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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-271/96-09
	ML20134N107
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	02/10/1997
From:	Conte R; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Reid D; VERMONT YANKEE NUCLEAR POWER CORP.
References
	NUDOCS 9702210204
	Download: ML20134N107 (3)
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February 10,1997

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Mr. Donald A. Reid

Vice President, Operations

Vermont Yankee Nuclear Power Corporation

RR 5, Box 169 -

Ferry Road

Brattleboro, VT 05301

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Subject: Inspection Report 50-271/96-09

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Dear Mr. Reid:

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This refers to thu vecember 20,1996 correspondence, in response to our letter dated

December 2,1996, regarding Vermont Yankee. This correspondence dealt with Notice of

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Violation 50-271/96-09-06.

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Thank you for informing us of your corrective actions. We have reviewed this matter in

accordance with NRC Inspection Manual Pr'ocedure 92902, Maintenance and 92903,

Engineering. We concur with your assessment of the root cause being deficient

communication between Design Engineering and the Maintenance Department and within

Design Engineering. The corrective actions you have taken or planned for the violation ;

documented in inspection report 96-09 appear to appropriately address the identified j

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surveillance test deficiency root and contributing causes. These corrective actions will be !

examined during a future inspection to assess their overall effectiveness. Although not I

" specifically referenced in your response, we note that your current design basis !

documentation initiative should bolster your efforts to improve the linkage between design !

basis information and current operating and test procedures. We urge you and your staff to

continue this initiative.

Your cooperation with us is appreciated. !

Sincerely,

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Fachard J. Conte, hief

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Projects Branch 5

Division of Reactor Projects

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9702210204 970210

PDR ADOCK 05000271 '

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Mr. Donald A. Reid

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Docket No. 50-271

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cc: i

R. McCullough, Operating Experience Coordinator - Vermont Yankee

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G. Maret, Plant Manager

J. Duffy, Licensing Engineer, Vermont Yankee Nuclear Power Corporation i

J. Gilroy, Director, Vermont Public Interest Research Group, Inc.

D. Tefft, Administrator, Bureau of Radiological Health, State of New Hampshire -

Chief, Safety Unit, Office of the Attorney General, Commonwealth of ,

Massachusetts ;

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cc with/ copy of Licensee's Response Letter:

R. Gad, Esquire .

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G. Bisbee, Esquire

T. Rapone, Massachusetts Executive Office of Public Safety

State of New Hampshire, SLO Designee :

State of Vermont, SLO Designee ;

Commonwealth of Massachusetts, SLO Designee

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Mr. Donald A. Reid 3

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Distribution w/ encl: !

Region I Docket Room (with concurrences) .

PUBLIC

Nuclear Safety Information Center (NSIC)

NRC Resident inspector

D. Screnci, PAO (2)

R. Conte, DRP

D. Beard, DRP

L. Harrison, DRS

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DOCUMENT NAME: Q:\ BRANCH 5\V9609.RSP I

To e e copy of this document, indicate in the box: "C" = Cop without attachment / enclosure *E' = Copy with attschment/ enclosure

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VERMONT YANKEE

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NUCLEAR POWER CORPORATION

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Ferry Road, Brattleboro. VT 05301-7002

,,m,y

) ENGINEERING OFFICE

ev 580 MAIN STREET

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BOLTON. MA 01740

(508) 779-6711

December 20.1996

BVY 96-161

United States Nuclear Regulatory Commission

ATTN: Document Control Desk

Washington, DC 20555

References: (a) License No. DPR-28 (Docket No. 50-271)

(b) Letter, USNRC to VYNPC. Notice of Violation - NRC Integrated Inspection

Report," NVY 96-181, dated 12/2/96

Subject: Reply to a Notice of Violation -Inspection Report '4o. 50-271/96-09

This letter is written in response to Reference (b) which documents that our activities were net

in full compliance with NRC requirements. The violation. classified as Seventy Level IV. was

identified during an NRC inspection conducted from September 16-20,1996. Our response to

the violation is provided below.

Violation

10 CFR Part 50, Appendix B, Criterion XI, " Test Control," requires written test procedures

which incorporate acceptance limits contained in applicable design documents. ANSI

N18.7-1976, Section 5.2.19.3, " Test Associated with Plant Maintenance, Modifications er

Procedure Changes," requires procedures to include appropriate quantitative or

qualitative acceptance criteria (limits) contained in applicable design documents. The VY

UFSAR, Section 1.9, states the VY Quality Assurance Program is in compliance with 10

CFR Part 50, Appendix B and ANSI N18.7-1976.

Contrary to the above, on and before September 20,1996, the licensee's surveillance

procedure, OP 4215, Rev. 6, " Main Station Battery Performance / Service Test," failed to

incorporate any appropriate acceptance criteria for the battery service test. The

acceptance criteria in the form of test shutdown voltage had no basis in any design

document. The battery test acceptance criteria failed to consider the minimum battery

terminal voltage used to determine the acceptable operation of safety-related de

equipment as documented in calculation VYC 1349, Rev. O, dated January 23,1995.

This is a Severity LevelIV violation.

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VERMONT YANKEE NUCLEAR POWER CORPORATION

United States Nuclear Regulatory Commission

December 20,1996

Page 2 of 3

Resconse:

1) Reason for the violation

Vermont Yankee does not contest this violation. The root cause of this violation was

deficient communication between Design Engineering and the Maintenance Department.

and within Design Engineering. The 125 VDC Voltage Drop Study, VYC-1349, was not

referenced in the maintenance test procedure nor were the minimum battery voltages

assumed in the study communicated to the Maintenance Department. Therefore, an

acpropnate acceptance enteria was not incorporated into the Main Station Battery

Performance / Service Test procedure (CP 4215). Insufficient guidance provided to the

preparer of the calculation, the need for enhanced procedural requirements and lack of

cwnership of VYC-1349 were identified as contributing causes.

2) Corrective steos that have been taken and the results achieved

a) A review of the Main Station Battery service test data recorded during the past refueling

outage was performed. As documented in the service test, the minimum voltage on

Batteries A and B was approximately 111 Vdc and 113 Vde, respectively. The 125

VDC Voltage Drop Study assumed a minimum voltage of 107 Vdc and 110 Vdc for

Batteries A and B, respectively. Therefore, the assumptions in VYC-1349 envelope the

test results and we conclude there are no operability concems associated with the Main

Station Batteries.

b) The 125 VDC Voltage Drop Study, VYC-1349, was evaluated in light of changes to the

Main Station Battery Sizing Calculation, VYC-298, and inspector comments. The

evaluation confirmed that sufficient voltage is available to operate DC loads from both

Batteries A and B.

c) The procedure which requires the ca!culation originator to review applicable FSAR,

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Technical Specifications, Procedures (Cperating, EOPs, Surveillance, Maintenance).

Technical Programs and Prints for impact has been distributed for review to all Design

Engineering staff to reinforce its requirements. This procedure was identified as a

failed barrier in the root cause analysis.

3) Corrective Steos that will be taken to avoid further violations

a) The 125 VDC Voltage Drop Study, VYC-1349, will be revised to be consistent with the

latest revision of the Main Station Battery Sizing Calculation, VYC-298. This is ,

expected to be complete by April 30,1997.

b) Appropriate acceptance criteria for battery minimum voltages will be incorporated into

procedure OP 4215. This is expected to be complete by June 30,1997.

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VERMONT YANKEE NUCLEAR POWER CORPORATION

United Stat:s Nuclear Regulatory Commission .

December 20,1996

Page 3 of 3

c) Vermont Yankee will review and revise existing procedural requirements regarding

changes to and ownership of design casis calculations. Specifically, the requirements

for assessing the impact of calculaticn changes on pending changes, other

calculations, procedures and other design basis documents and the requirements for

communicating these changes will be reviewed. Training and implementation of the

revised procedural guidance is expected to be complete by April 30,1997.

d) Surveillance procedures associated with the batteries defined in Vermont Yankee

Technical Specifications will be reviewed against the applicable design bases

calculations to ensure consistency. This is expected to be complete by April 30,1997.

4) Date by which full comoliance will be achieved:

Vermont Yankee will have achieved full compliance once the main station battery

calculations and procedure OP 4215 are revised to include an acceptance criteria

consistent with the design basis of the DC system. These revisions are expected to be

completed by June 30,1997, well before the next use of procedure OP 4215 during the

Spring 1998 refueling outage. ,

We trust that the information provided is acceptable. However, should you have any questions I

or desire any additionalinformation, please contact this office.

Sincerely,

VERMCNT YANKEE NUCLEAR POWER CORPOPATlCN

Dcnald A. Reid

Vice President, Operations

C: USNRC Region i Administrator--

USNRC Project Manager- VYNPS

USNRC Resident inspector- VYNPS

ML20134N107

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